Red Aloe Privacy Policy

Red Aloe is committed to protecting your privacy and we take great care with your personal information. This policy will help you understand how we use and protect your data. If you have any questions, feel free to contact us at info@redaloe.com.

1. Introduction

Red Aloe (“us,” “we,” or “Red Aloe”) is committed to respecting the privacy rights of our customers, visitors, and other users of RedAloe.com (the “Site”) and related websites, applications, services and mobile applications provided by Red Aloe and on/in which this Privacy Policy is posted or referenced (collectively, the “Services”). We created this Privacy Policy (“Privacy Policy”) to give you confidence as you use the Services and to demonstrate our commitment to the protection of privacy. This Privacy Policy is only applicable to the Services. This Privacy Policy does not apply to any other website or digital service that you may be able to access through the Services or any website or digital services of Red Aloe’s business partners, each of which may have data collection, storage and use practices and policies that may differ from this Privacy Policy. Your use of the Services is governed by this Privacy Policy and the Terms of Service posted on RedAloe.com. Any capitalized term used but not defined in this Privacy Policy shall have the meaning in the Agreement.

BY USING THE SERVICES, YOU AGREE TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU CANNOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

2. Information We Collect

2.1 Personal Information Generally

Some of the Services require us to learn more about you so that we can best meet your needs. When you access the Services, we may ask you to voluntarily provide us certain information that personally identifies you or could be used to personally identify you (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information: (1) contact data (such as your e-mail address and phone number); (2) demographic data (such as your gender, your date of birth and your zip code); and (3) other identifying information that you voluntarily choose to provide to us, including without limitation unique identifiers such as passwords, and Personal Information in emails or letters that you send to us. We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent. You may still access and use some of the Services if you choose not to provide us with any Personal Information, but features of the Services that require your Personal Information will not be accessible to you.

2.2 Billing, Collection and Payment Information

When you make a payment through our Services to a Professional (as further described in and subject to other provisions of the Agreement), your payment card information is processed by our payment processing partner, such as Stripe (https://stripe.com). Our payment processing partner collects your voluntarily provided payment card information necessary to process your payment. Such partner’s use and storage of information it collects is governed by its applicable terms of service and privacy policy. The information we store includes your payment card type and the last four digits of the payment card.

2.3 Traffic Data

We also may automatically collect certain data when you use the Services, such as (1) IP address; (2) domain server; (3) type of device(s) used to access the Services; (4) web browser(s) used to access the Services; (5) referring webpage or other source through which you accessed the Services; (6) geolocation information; and (7) other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.

2.4 HIPAA and PHI

Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some demographic, health and/or health-related information that Red Aloe collects as part of providing the Services may be considered “protected health information” or “PHI.” Specifically, when Red Aloe receives identifiable information about you from or on behalf of your Healthcare Providers, this information is considered PHI.

Red Aloe professionals utilize tools that are provided either by Red Aloe or by third-party-providers (example: WeCounsel.com) that provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. Red Aloe and the professionals that utilize the Red Aloe service may only use and disclose your PHI in the ways permitted by your Healthcare Provider(s).

3. How We Collect Information

We collect information (including Personal Information and Traffic Data) when you use and interact with the Services, and in some cases from third party sources. Such means of collection include:

When you use the Services’ interactive tools and services, such as searching for Professionals, searching for available appointments with Professionals and completing medical history forms (“Medical History Forms”) prior to Healthcare Provider appointments;

When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys, questionnaires and the like;

If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices;

If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable;

Through cookies, web beacons, website analytics services and other tracking technology (collectively, “Tracking Tools”), as described below; and

When you use the “Contact Us” function on the Site, send us an email or otherwise contact us.

4. Tracking Tools and “Do Not Track”

4.1. Tracking Tools

We may use tools outlined below in order to provide our Services to, advertise to, and to better understand users.

Cookies: “Cookies” are small computer files transferred to your computing device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Services. We use Cookies to improve or tailor the Services or customize advertisements by tracking navigation habits, measuring performance, storing authentication status so re-entering credentials is not required, customizing user experiences with the Services and for analytics and fraud prevention. For more information on cookies, visit http://www.allaboutcookies.org.

Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Services, the websites of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Services, using selected publishers’ websites or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).

Website Analytics: We may use third-party website analytics services in connection with the Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Site. We use the information collected from these services to help make the Services easier to use and as otherwise set forth in Section 5 (Use of Information).These website analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across websites that do not use their services.

Mobile Device Identifiers: As with other Tracking Tools, mobile device identifiers help Red Aloe learn more about our users’ demographics and internet behaviors. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and Traffic Data.

Cross Device Matching: To determine if users have interacted with content across multiple devices and to match such devices, we may work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we may also provide de-identified data these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.

4.2. Tracking Tools

We may use a type of advertising commonly known as interest-based or online behavioral advertising. This means that some of our partners use Tracking Tools to display Red Aloe ads on other websites or services based on information about your use of the Services or your interests (as inferred from online activity). Such partners may include third-party service providers, advertisers, advertising networks or platforms, and agencies. Other Tracking Tools used by our partners may collect information when you use the Services, such as IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. These Tracking Tools help Red Aloe learn more about our users’ demographics and internet behaviors.

4.3. Options for Opting out of Cookies and Mobile Device Identifiers

Some web browsers (including some mobile web browsers) allow you to reject Cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Red Aloe’s Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

You may opt out of receiving certain Cookies and certain trackers by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) consumer opt-out page or by installing the DAA’s AppChoice app (for iOS or Android) on your mobile computing device. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete Cookies on your computer, tablet or mobile computing device, you may need to opt out again. For information about how to opt out of interest-based advertising on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device. You will need to opt out of each browser and device for which you desire to apply these opt-out features.

Please note that even after opting out of interest-based advertising, you may still see Red Aloe advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that Red Aloe is no longer using Tracking Tools — Red Aloe still may collect information about your use of the Services even after you have opted out of interest-based advertisements and may still serve advertisements to you via the Services based on information it collects via the Services.

5. Use of Information

We may use information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) to better understand who uses Red Aloe and how we can deliver a better experience (for example, testing different kinds of emails has helped us understand when and how patients prefer to get Wellness Reminders for preventive care), or otherwise at our discretion.

We use information, including Personal Information, to provide the Services and to help improve the Services, to develop new services, and to advertise (for example, to display Red Aloe ads on other websites). Such use may include:

Providing you with the products, services and information you request;

Responding to correspondence that we receive from you;

Contacting you when necessary or requested, including to remind you of an upcoming appointment;

Providing, maintaining, administering or expanding the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;

Customizing or tailoring your experience of the Services, which may include sending customized messages or showing you Sponsored Results;

Notifying you about certain resources, Healthcare Providers or services we think you may be interested in learning more about;

Sending you information about Red Aloe or our products or Services;

Sending emails and other communications that display content that we think will interest you and according to your preferences;

Combining information received from third parties with information that we have from or about you and use the combined information for any of the purposes described in this Privacy Policy;

Showing you advertisements, including interest-based or online behavioral advertising;

Using statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts; and

6. Disclosure of Information

In certain circumstances, and in order to perform the Services, we may disclose certain information that we collect from you:

Provided that you choose to use the applicable Services, we may share your Personal Information with your Professionals to enable them to refer you to and make appointments with other Professionals on your behalf or to perform analyses on potential health issues or treatments.

We may share your Personal Information with Professionals in the event of an emergency.

We do not sell email addresses to third parties. We may share your Personal Information with our partners to customize or display our advertising.

We may share your Personal Information and Traffic Data with our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, Website analytics, or ad serving) and/or who make certain services, features or functionality available to our users.

We may share your Personal Information with the insurance provider you identify to us (and via our partners) to determine eligibility and cost-sharing obligations, and otherwise obtain benefit plan information on your behalf.

We may transfer your information to another company in connection with a merger, sale, acquisition or other change of ownership or control by or of Red Aloe (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

We also may need to disclose your Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (1) comply with or fulfill our obligations under applicable law, regulation, court order or other legal process; (2) protect the rights, property or safety of you, Red Aloe or another party; (3) enforce the Agreement or other agreements with you; or (4) respond to claims that any posting or other content violates third-party rights.

We may disclose information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) at our discretion.

7. Public Information

You agree that any information that you may reveal in a review posting or online discussion or forum is intentionally open to the public and is not in any way private. We recommend that you carefully consider whether to disclose any Personal Information in any public posting or forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.

8. Storage and Security of Information

The security of your Personal Information is important to us. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. For example, when you enter sensitive information on our Site, we encrypt that information using Secure Socket Layer (SSL) technology.

We store and process your information on our servers in the United States and abroad. We maintain industry standard backup and archival systems.

Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can update that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at info@redaloe.com. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

9. Controlling Your Personal Information & Notifications

If you are a registered user of the Services, you can modify certain Personal Information or account information by logging in and accessing your account. If you wish to close your account, please email us at info@redaloe.com. Red Aloe will delete your account and the related information at your request as soon as reasonably possible. Please note, however, that Red Aloe reserves the right to retain information from closed accounts, including to comply with law, prevent fraud, resolve disputes, enforce the Agreement and take other actions permitted by law.

You must promptly notify us if any of your account data is lost, stolen or used without permission.

10. Information Provided on Behalf of Children and Others

The Services are not intended for use by children and children are prohibited from using the Services. Red Aloe does not knowingly collect any information from children.

By accessing, using and/or submitting information to or through the Services, you represent that you are not younger than age thirteen (13). If we learn that we have received any information directly from a child under age thirteen (13) without his/her parent’s written consent, we will use that information only to respond directly to that child (or his/her parent or legal guardian) to inform the child that he/she cannot use the Services, and we will subsequently delete that information.

If you are between age thirteen (13) and the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. If you are a parent or legal guardian of a minor child, you may, in compliance with the Agreement, use the Services on behalf of such minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Information as otherwise provided herein.

If you use the Services on behalf of another person, regardless of age, you agree that Red Aloe may contact you for any communication made in connection with providing the Services or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Services on behalf.

11. Other Websites

The Services contain links to or embedded content from third party website. A link to or embedded content from a non-Red Aloe website does not mean that we endorse that website, the quality or accuracy of information presented on the non-Red Aloe website or the persons or entities associated with the non-Red Aloe website. If you decide to visit a third party website, you are subject to the privacy policy of the third party website as applicable and we are not responsible for the policies and practices of the third party website. We encourage you to ask questions before you disclose your information to others.

You may have arrived at the Services from, or began your use of the Services at, a third party website, including a third party website that links to Red Aloe or embeds Red Aloe content. The presence of such links or content on third party websites does not mean that we endorse that website, the quality or accuracy of information presented on the non-Red Aloe website or the persons or entities associated with the non-Red Aloe website. You may be subject to the privacy policy of the third party website as applicable and we are not responsible for the policies and practices of the third party websites. In addition, the policies and practices of third parties do not apply to your information, including Personal Information, obtained pursuant to this Privacy Policy.

12. Updates and Changes to Privacy Policy

The effective date of this Privacy Policy is set forth at the top of this webpage. We will notify you of any material change by posting notice on this webpage. Your continued use of the Services after the effective date constitutes your acceptance of the amended Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices. Any amended Privacy Policy supersedes all previous versions. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES.

13. Contacts

If you have any comments, concerns or questions about this Privacy Policy, please contact us at info@redaloe.com or at:

About Red Aloe Professionals

I. Introduction

All Red Aloe professionals and before joining the Red Aloe network, the stated credentials for those professionals are verified to ensure that our clients understand the qualification levels of the professional/service provider that they are engaging. Our professionals all adhere to the ethical codes of their respective licensing or professional organizations.

Encryption and Information Security

Any records stored on either the cloud or on physical storage media must be encrypted and secured against unauthorized access. Red Aloe’s professional tools allow professionals to store and transmit client data on a network with at least 128 bit encryption. Red Aloe tells its professionals that physical storage devices such as a computer hard drive, USB or mobile device must be stored in a locked location with precautions taken against any unauthorized physical or electronic access. Any WiFi networks used must be encrypted.

Using public, shared computers is never permitted, regardless of security or encryption tools used. If a counselor uses a laptop computer, it must have a master password enabled along with special attention paid to the computer’s physical storage and security.

Passwords

Passwords must be changed regularly. All counselors are encouraged to change their Red Aloe passwords monthly and are encouraged to change any passwords related to client records at least monthly. Passwords must be at minimum 11 characters long with both upper and lower case letters, at least 2 different numbers and 2 special characters.

Any variation of the counselor’s name, social security number, address, etc. must not be used. Professionals are encouraged not to store their Red Aloe password on their computer.

Professionals should ensure that they use appropriate firewall protection to ensure no unauthorized network connections to their computer.

Virus Protection

Professionals are highly encouraged to use Mac OS or Linux systems to minimize security vulnerabilities. Windows users are required to use up-to-date anti-virus software and download the most current Windows security updates within 1 week of release. Professionals are also encouraged to avoid any websites of a questionable or risky nature. All professionals, regardless of computer operating system, are highly discouraged from using any public, peer-to-peer file sharing services.

Red Aloe will stay current on security risks for counselors and users and inform the Red Aloecommunity as appropriate, however all professionals have the ultimate responsibility of ensuring their machine is safe and secure.

Hardware

Professionals must be comfortable and familiar with their particular hardware.

Software

Professionals must be comfortable with both the Red Aloe platform and any software necessary to assist clients during therapy.

III. Professionals must work only within their scope of practice.

Scope of Practice indicates the specific area in which a professional may practice. Professionals may not practice within an area for which they are not trained and/or licensed. Professionals must follow the laws and professional regulations for their locale.

Professionals are required to answer any questions about their qualifications, training and/or licensing so a client can be fully informed. Professionals are expressly prohibited from providing any service for which they are not qualified or legally allowed to provide.

IV. Professionals must ensure that their skills are current.

Professionals must stay current within their professional area. This includes receiving any required continuing education training. Professionals must keep abreast of significant research within their field and be able to employ new training, knowledge and research towards the betterment of their clients. Professionals must keep their licenses and certifications current as required by their local jurisdiction.

V. The Professional is the Owner of the Record

Red Aloe does not store, maintain or transmit client records other than the initial sign up screening form. Red Aloe does maintain a payment history, however no other treatment data is collected by Red Aloe. The professional is the legal owner of the medical records created and generated from consultations. Professionals must comply with any medical records release requests by a client or legally authorized entity (where applicable). Counselors must maintain patient records as required by law within their jurisdiction and make available any records if requested by a client. No records shall ever be released without a written release from the client or client’s legally authorized agent.